Contagion – Starting in the Middle

Yesterday, we say Contagion, a frighteningly realistic depiction of what would happen if there was a worldwide pandemic. The movie does not begin on the first day of the disease, explaining its origin. Rather it starts a couple of days later, leaving the viewer and the scientists in the dark about how it started. By starting something in the middle, you leave others guessing and off-balanced. This approach may be used in depositions, when you want to keep a witness off-balance and guessing as to what you'll be asking next. Depositions generally follow the same pattern – the introductions, background information, going over the witness's knowledge about the case at hand, generally all done in chronological order. Often the witness can guess the next question (or next series of questions). If you're hoping to secure an admission in deposition, you're more likely to secure it if the deponent doesn't see the question coming. You may want to consider starting your deposition in the middle, where you jump to the key questions first before the witness gets into a rhythm of answering your questions. This approach may not only surprise the witness but may surprise you as well when you get the answers you were hoping for. Share this: Twitter LinkedIn Email Digg Reddit StumbleUpon Facebook Like this: Be the first to like this post.

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